""WALGREEN IS WITHOUT SUFFICIENT KNOWLEDGE OR INFORMATION TO FORM A BELIEF AS TO THE TRUTH OF THE ALLEGATION"". THIS IS REPEATED SIX TIMES! THEY ARE CULPABLE AND THEY AND THEIR PATENT ATTORNEYS/LEGAL ATTORNEYS KNOW IT..GUILTY AS CHARGED, AND PROBABLY CONTINUATIONS UNTIL JUDGE FORCES THE ISSUE!..Just my opinion of course and I feel I am right on the money..Tiffer END
1. Walgreen is without sufficient knowledge or information to form a belief as to the truth of the allegations in Paragraph 1 of the Complaint and, therefore, denies each and every allegation set forth therein on that basis.
2. Walgreen admits the allegations in Paragraph 2.
3. In response to Paragraph 3 of the Complaint, Walgreen admits that the Complaint purports to state a claim for patent infringement but denies any wrongdoing or liability under the patent laws and further denies that Plaintiff is
owed any damages thereunder.
4. In response to Paragraph 4 of the Complaint, Walgreen admits that the Court has jurisdiction over it. Walgreen denies the remaining allegations in Paragraph 4 of the Complaint.
5. In response to Paragraph 5 of the Complaint, Walgreen admits that venue is proper in this Court. Walgreen denies the remaining allegations in Paragraph 5 of the Complaint.
6. Walgreen is without sufficient knowledge or information to form a belief as to the truth of the allegations in Paragraph 6 of the Complaint and,therefore, denies each and every allegation set forth therein on that basis.
7. Walgreen is without sufficient knowledge or information to form a belief as to the truth of the allegations in Paragraph 7 of the Complaint and, therefore, denies each and every allegation set forth therein on that basis.
8. Walgreen is without sufficient knowledge or information to form a belief as to the truth of the allegations in Paragraph 8 of the Complaint and, therefore, denies each and every allegation set forth therein on that basis.
9. Walgreen is without sufficient knowledge or information to form a belief as to the truth of the allegations in Paragraph 9 of the Complaint and,therefore, denies each and every allegation set forth therein on that basis.
10. Walgreen is without sufficient knowledge or information to form a belief as to the truth of the allegations in Paragraph 10 of the Complaint, and, therefore, denies each and every allegation set forth therein on that basis.
11. Walgreen admits that, together with its subsidiaries, it operates the largest drugstore chain in the United States with net sales of $71.6 billion in the fiscal year ended August 31, 2012. Walgreen admits that as of August 31, 2012, it operated 8,385 locations (including 7,930 drugstores) in 50 states, the District of Columbia, Guam, and Puerto Rico. Walgreen admits that it provides millions of customers with pharmacy, health and wellbeing solutions. Walgreen admits that one of its goals is to be the first choice for health and daily living in thecommunities it serves. Except as expressly admitted, above, the allegations in
Paragraph 11 are denied.
12. Walgreen’s public statements speak for themselves. Consequently, the allegations in Paragraph 12 are denied.
13. Walgreen admits that it offers its customers the ability to manage their medical prescriptions through a secure online account and that said account requires a user name and password. Walgreen admits that a customer may add family members to the account and manage multiple prescriptions from a single account. Walgreen denies the remaining allegations in Paragraph 13 of the
Complaint.
14. Walgreen admits that a customer may bring a written copy of a
prescription and a physician may call in or fax a prescription to a Walgreen pharmacy, and it can be added
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